ENRIO Handbook Recommendations for the investigation of Research Misconduct (March 2019)
Who and what is ENRIO? A more than 10 ‐ year old network. Today consisting of some 30 independent members (working with and committed to RI) from 23 European countries. No one can instruct ENRIO ENRIO aims to: Promote exchange of information and experiences between the members Share information and good practices in raising awareness Promote training and education with regard to research integrity Support and advise countries that lack a national structure Build relationship with other organisations with European or global interests in research integrity Share knowledge in handling allegations of research misconduct
Background Through the years ENRIO, and other European bodies engaged in RI, have been confronted with a very diversified picture when it comes to dealing with research misconduct. You will find countries/institutions with well established procedures, structures etc. Then you will find European countries (and or research institutions) with almost no tradition or guidelines for handling cases and committed people struggling for improvements. This Handbook is primarily meant to assist the latter group but also meant for potential revisions of existing policies etc. Perhaps it could be inspirational for discussions beyond Europe? It is based on discussions by a working group which reflects the diversity and the fact that no one model fits all due to different cultural, social , political and legal differences across European countries. Consensus: A need for non ‐ binding advice or soft ‐ harmonization and a lot to learn from each other.
A triggering starting point In 2017, the European Code for Research Integrity was revised by ALLEA (All European Academies). ENRIO endorses the CoC and its principles about RI as such including investigation processes. However, the CoC triggered a long known need for more detailed recommendations or considerations on how to deal with research misconduct AND other unacceptable practices
The Handbook in short Specific recommendations or things to consider: Step by step Comments, explanations etc. Overarching principles Discussions of important issues
Content Preamble RECOMMENDATIONS 1. Code of conduct (Guidelines) 2. Definition of research misconduct and other unacceptable/irresponsible practices 3. Setting up or improving a Research Integrity (RI) system 4. Conflicts of interest 5. Composition and competence of investigation committees 6. Transparency versus confidentiality 7. Receiving allegations or concerns including guidance 8. Handling allegations 9. Appeal or second opinion 10. Sanctions and follow ‐ up 11. Dissemination and communication during and after an investigation 12. Reactions to possible systemic problems revealed by an investigation 13. Cross Boundary allegations/investigations 14. How to learn from each other Procedures: Overarching/core principles
1. Code of conduct (Guidelines) A national addendum to the European Code of Conduct (CoC) or more detailed and specific national, local and/or field specific guidelines (CoC) is a benefit and is therefore recommended. 2. Definition of research misconduct and other unacceptable/irresponsible practices A description or definition of research misconduct and unacceptable practices should be included in national or local guidelines/code of conduct. If not, specific descriptions or definitions should be outlined in other relevant documents, e.g. in legislation, agreements, policies and procedures, etc.
3. Setting up or improving a Research Integrity (RI) system A uniform and robust system for dealing with research misconduct (including major and minor breaches of good scientific/research practice) should be adopted in each European country. Main responsibility could be mainly local or mainly national. Governmental agencies, national funding bodies, private foundations, research institutions etc. could all have a leading role. However, division of responsibility should be clear. Every institution/body must have clearly stated written procedures. It is of utmost importance that once a national and/or local committee or the like is appointed, no outside influence or interference should be allowed to affect the process or outcome of investigations, conclusions etc. It is recommended to have a national oversight body. (Is discussed in detail)
4. Conflicts of interets CoI should be documented and handled in a transparent fashion during the whole investigation process 5. Composition and competence of investigation committees When setting up a system (committees or the like) for dealing with research misconduct, there should be a clear mandate. To diminish risk of bias, local committees should include independent members from outside the institution in question. National committees/bodies should consider including independent members from other countries. It is recommended to have standing committees as opposed to ad hoc committees. (Discussed in detail).
6. Transparency versus confidentiality Transparency and openness should prevail provided this does not conflict with (national) regulations etc. Serious allegations should not be handled behind closed doors. 7. Receiving allegations or concerns including guidance Personal guidance for possible complainants – i.e. before launching a complaint – should be available. This could, for example, be offered by an ombudsperson or other trusted “neutral” person. How to make an allegation (in good faith) and to whom one can turn to (contact point) either at the appropriate level (e.g. local or national level) should be clear and well communicated. 8. Handling allegations It is highly recommended that all allegations (substantive or grounded suspicions) regarding research misconduct (such as FFP or similar serious breaches) are dealt with according to relevant Code of Conduct/overall guidelines and specified procedures. Irresponsible or unacceptable research practices should also be addressed although not necessarily in the same manner as investigations of serious breaches defined as research misconduct.
9. Appeal or second opinion The possibility of appeal differs across countries 10. Sanctions and follow ‐ up It is recommended that procedures regarding sanctions are set out, and that those sanctions are made known as part of a policy. Time limits should be considered for each kind of sanction. 11. Dissemination and communication during and after an investigation A policy regarding dissemination and communication during and after an investigation should be considered. It is recommended to be cautious to reveal the outcome of an investigation if an appeal can be expected.
12. Reactions to possible systemic problems revealed by an investigation It is recommended that possible systemic problems revealed by an investigation should be handled. The reasons and background for research misconduct (or repeated violations of good practices) should be discussed and evaluated thoroughly. The main purpose is to try to prevent this from happening again. Furthermore, lessons should be incorporated in institutional research integrity programmes or guidelines to help improve the research culture.
13. Cross Boundary allegations/investigations It is recommended to establish agreements early in collaborative (especially cross ‐ institutional and cross ‐ boundary) projects. Accordingly, it is recommended to follow OECD guidelines and the Montreal statement. It is further recommended that relevant guidelines/procedures should deal with cross boundary allegations within the country in question. Legal aspects need to be taken into consideration. 14. How to learn from each other Annual national reports (in English) describing specific (but anonymized) investigations and possible breaches of responsible research practices, findings, main discussions and challenges about RI ‐ principles etc. should be made public in an aggregated way so others can learn from trends, etc.
What’s next? Feedback, evaluation and revision
Thanks to: The ENRIO working group The Austrian Agency for RI ENERI/The European Commission Any others who have contributed and Thanks for your attention Torkild Vinther Chair of the ENRIO Working Group Investigation
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